During our recent webinar (now available on-demand), we provided an in-depth tour through the findings of our 2015 Ethics & Compliance Training Benchmark Report.
Webinar attendees asked a number of valuable questions on ethics and compliance training best practices. Below are ten of the top audience questions answered.
Our FAQ document, which includes answers to all questions posed during the webinar, along with the webinar recording and slides can be accessed here.
1) What can I do when senior management feels they don't need training? Do you have advice on how to engage them?
Senior leaders tend to respond to proof in the form of metrics and data. Show them the positive impact training has (or could be having) on culture and that it provides a return on investment. (Our By the Numbers business case may help.) It can also be effective to cite case studies of organizations of a similar size, and perhaps in a similar industry as yours whose poor “tone at the top” and resulting corporate culture created negative financial or reputational effects. Unfortunately, these examples are very easy to find.
2) Does NAVEX Global have a survey or questionnaire available to provide to staff to further evaluate organizational training culture?
We have two tools that may be helpful. One is a white paper titled “Creating a Culture of Ethics, Integrity & Compliance: Seven Steps to Success” that includes key criteria for strong cultures. The other is a checklist we put together for boards to use to evaluate their organization’s compliance program. It includes a section on culture. This checklist is located in the blog article here: “Real Guidance (Finally) On the Compliance Oversight Role of Boards.” Our advisory services team also routinely develops and deploys surveys for organizations looking to survey employees about culture.
Our Advisory Services team also provides organizational culture assessments, and would be happy to consult with you about your needs.
3) How do you measure training effectiveness?
To truly demonstrate the ROI of a training program—and advocate for the resources they need to make it even more effective—compliance professionals must carefully consider the metrics they use. This exercise should be done in conjunction with senior leaders, and align to organizational values, goals and risks.
While it is not feasible to adopt every possible metric for measuring effectiveness, organizations need to move toward incorporating more meaningful effectiveness measurements (beyond training completion rates) and then budget and plan for collecting and analyzing the data. Over time, we hope to see organizations using more powerful and meaningful metrics, such as:
- Pre-training quizzes
- Post-training quizzes
- Satisfaction surveys
- Changes in behaviors
Our Advisory Services team would be happy to consult with you about your measurement goals.
4) Can you repeat what you said in regards to senior management training on Bribery and Corruption?
On the webinar, I had expressed surprise that only 41 percent of respondents to our 2015 Ethics & Compliance Training Benchmark Report are training on the topic of bribery and corruption. This is a very significant risk for any organization that does business globally, or interacts with foreign governments (even if business operations are exclusively domestic). All employees in these organizations—including senior leaders who are in a position to expose their organization to massive risk—should be trained on this topic.
5) What do you do when your organization has no foundational elements in place for an ethics and compliance training program? i.e. no ethics training budget, no internal audit function, no hotline, no training on policies, etc. Suggestions or ideas?
If you are working to build a program from the ground up—or reinvigorate a current program—the most important thing you can do is to get senior leadership to support the need for a training program and to allocate budget and time to building it. Convincing reluctant senior leaders can be very difficult; often you must present your leaders with the data and information that demonstrates the legal obligation to train, the benefits of training (litigation avoidance, improved settlement positions, etc.), and show the importance of training as part of an overall compliance program.
Our By the Numbers business case for training may help you gather some of the data points you need. In addition, many surveys (especially the National Business Ethics Survey by the Ethics Research Center) will show the strong connection between an ethical culture and strong business performance.
Do you have additional questions on training best practices? Comment on this post and we’ll address them here—or feel free to contact us at any time for a consultation.